RA-13-099, Request for Exemption from the Biennial Emergency Preparedness Exercise Requirements in 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c

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Request for Exemption from the Biennial Emergency Preparedness Exercise Requirements in 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c
ML13288A177
Person / Time
Site: Oyster Creek
Issue date: 10/14/2013
From: David Helker
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-13-099
Download: ML13288A177 (42)
v • d • e


Text

10 CFR 50.12 RA-13-099 October 14, 2013 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219

SUBJECT:

Oyster Creek Nuclear Generating Station Request for Exemption from the Biennial Emergency Preparedness Exercise Requirements in 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c Pursuant to 10 CFR 50.12, "Specific exemptions," Exelon Generation Company, LLC (Exelon),

the licensee for Oyster Creek Nuclear Generating Station (OCNGS) requests the U.S. Nuclear Regulatory Commission (NRC) approval of an exemption from the requirements of 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities, /I Sections IV.F.2.b and IV.F.2.c. Specifically, Exelon requests postponement of OCNGS's full-participation biennial Emergency Preparedness (EP) exercise, which was scheduled to be conducted on October 8, 2013.

On October 1, 2013, the Federal government began to shutdown various government agencies due to a lapse in funding appropriations. On October 3, 2013, the New Jersey Office of Emergency Management (NJOEM) was advised by the Federal Emergency Management Agency (FEMA) Region 1\ Acting Regional Administrator that due to the funding constraints, FEMA travel was cancelled except for life saving purposes. The cancellation of Federal travel resulted in FEMA being unable to evaluate the OCNGS full-participation EP exercise on October 8, 2013. Exelon received similar notification from FEMA by letter dated October 9, 2013, regarding the agency's inability to support the scheduled OCNGS exercise. The government shutdown also affected the NRC's capabilities to participate in the scheduled exercise, although NRC personnel would have been available to evaluate during the exercise.

Accordingly, this exemption is being pursued as a result of the restrictions placed on the FEMA and NRC by the Federal government shutdown, which has impacted the ability of these agencies to participate in the October 8, 2013, OCNGS full-participation biennial EP exercise. to this letter provides the detailed basis and justification for this exemption request and addresses the exemption requirements of 10 CFR 50.12 and the guidance criteria contained in Regulatory Issue Summary (RIS) 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements." Attachment 2

10 CFR 50.12 Docket No. 50~219 October 14, 2013 Page 2 contains a letter from FEMA dated November 16, 2012, conceming the evaluation of the September 27, 2011, and June 12, 2012, OCNGS EP exercises. Attachments 3 and 4 contain letters from FEMA dated October 3, 2013, and October 10, 2013, concerning the deferral of the 2013 OCNGS EP exercise until March 2014. In addition, Attachment 5 includes an NJOEM letter dated October 9, 2013, pertaining to the deferral of the exercise until March 2014.

Further, Attachment 6 includes a FEMA letter dated May, 9, 2013, concerning the State of New Jersey's annual certification.

It is requested that NRC grant this exemption by December 31, 2013. This exemption request contains no new regulatory commitments.

If you have any questions or require additional information, please contact Vince Cwietniewicz (Emergency Preparedness Manager - Mid-Atlantic) at 610-765-5035.

Respectfully, David P. Helker Manager, licenSing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Request for Exemption Related to 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c

2. Letter from Federal Emergency Management Agency to New Jersey Emergency Management Section, dated November 16, 2012
3. Letter from Federal Emergency Management Agency to New Jersey Deputy Superintendent Homeland Security, State Police Division Headquarters, dated October 10, 2013
4. Letter from Federal Emergency Management Agency to New Jersey Deputy Superintendent Homeland Security, State Police Division Headquarters, dated October 3, 2013
5. Letter from New Jersey Office of Emergency Management to Exelon Emergency Preparedness Manager - Mid-Atlantic, dated October 9, 2013
6. Letter from Federal Emergency Management Agency to Commanding Officer, New Jersey Emergency Management Section, dated May 9, 2013 cc: Regional Administrator - NRC Region I w/attachments NRC Senior Resident Inspector - OCNGS NRC Project Manager, NRR - OCNGS

ATTACHMENT 1 Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Exemption Related to 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c

ATTACHMENT 1 Request for Exemption Related to 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c Purpose The following information provides the basis for an exemption request from the requirements of 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities, Sections IV.F.2.b and IV.F.2.c. Specifically, Exelon Generation Company, LLC II (Exelon) is requesting to postpone and reschedule the Oyster Creek Nuclear Generating Station (OCNGS) Emergency Preparedness (EP) full~participation biennial exercise from October 8, 2013, until March 18, 2014. This exemption request is being submitted as a result of the special circumstances caused by the Federal government shutdown and the resulting inability of U.S.

Nuclear Regulatory Commission (NRC) personnel to participate (Le., incident response team members) and Federal Emergency Management Agency (FEMA) representatives to evaluate the pertinent onsite and offsite portions of the scheduled OCNGS EP exercise. However, NRC representatives would have been available to evaluate during the exercise. This request for exemption is consistent with the guidance specified in Regulatory Issue Summary (RIS) 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements," dated February 24, 2006.

10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c stipulate the following:

2. The plan shall describe provisions for the conduct of emergency preparedness exercises as follows: Exercises shall test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communications networks, test the public alert and notification system, and ensure that emergency organization personnel are familiar with their duties.
b. Each licensee at each site shall conduct a subsequent exercise of its onsite emergency plan every 2 years. Nuclear power reactor licensees shall submit exercise scenarios under § 50.4 at least 60 days before use in an exercise required by this paragraph 2.b. The exercise may be included in the full participation biennial exercise required by paragraph 2.c. of this section. In addition, the licensee shall take actions necessary to ensure that adequate emergency response capabilities are maintained during the interval between biennial exercises by conducting drills, including at least one drill involving a combination of some of the principal functional areas of the licensee's onsite emergency response capabilities. The prinCipal functional areas of emergency response include activities such as management and coordination of emergency response, accident assessment, event classification, notification of offsite authorities, assessment of the onsite and offsite impact of radiological releases, protective action recommendation development, protective action decision making, plant system repair and mitigative action implementation. During these drills, activation of all of the licensee's emergency response facilities (Technical Support Center (TSC), Operations Support Center (OSC), and the Emergency Operations Facility (EOF)) would not be necessary, licensees would have the opportunity to consider accident management strategies, supervised instruction would be permitted, operating staff in al/ participating facilities would have the

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix Section IV.F.2.b and IV.F.2.c Page 2 of 21 opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills may focus on the onsite exercise training objectives.

c. Offsite plans for each site shall be exercised biennially with full participation by each offsife authority having a role under the radiological response plan. Where the offsite authority has a role under a radiological response plan for more than one site, it shall fully participate in one exercise every two years and shall, at least, partially participate in other offs/te plan exercises in this period. If two different licensees each have licensed facilities located either on the same site or on adjacent, contiguous sites, and share most of the elements defining co-located licensees, then each licensee shall:

(1) Conduct an exercise biennially of its onsite emergency plan; (2) Participate quadrennially in an offsite biennial full or partial participation exercise; (3) Conduct emergency preparedness activities and interactions in the years between its participation in the offsite full or partial participation exercise with offsite authorities, to test and maintain interface among the affected State and local authorities and the licensee. Co-located licensees shall also participate in emergency preparedness activities and interaction with offsite authorities for the period between exercises; (4) Conduct a hostile action exercise of its onsite emergency plan in each exercise cycle; and (5) Participate in an offsite biennial full or partial participation hostile action exercise in alternating exercise cycles.

Special Circumstances OCNGS was scheduled to conduct a full-participation, FEMA-evaluated, EP biennial exercise on October 8, 2013. However, on October 1, 2013, the Federal government began a shutdown due to a lapse of funding appropriations for government agencies. The government shutdown placed restrictions on FEMA and the NRC. This affected the ability of FEMA representatives scheduled to evaluate and NRC personnel scheduled to participate (Le., NRC incident response team members) during the 2013 biennial EP exercise at OCNGS. However, NRC staff would have been available to evaluate. This government shutdown created special circumstances that resulted in the unavoidable cancellation of the EP exercise, since personnel from key government agencies were unavailable.

NRC RIS 2006-03 states that, to accommodate the scheduling of exercises, the NRC has allowed licensees the flexibility to schedule their exercises at any time during the biennial calendar year. OCNGS typically conducts its EP full-participation biennial exercises in the fall of odd numbered years (e.g., 2011, 2013, etc.). OCNGS coordinates and selects this time frame during scheduling conferences, which take into consideration the scheduling aspects of other EP exercises in NRC Region I, FEMA resources, and resources of offsite emergency response organizations from the State of New Jersey.

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 3 of 21 The last OCNGS EP full-participation biennial exercise was conducted on September 27, 2011.

This exercise involved NRC evaluation of the onsite emergency response functions and capabilities at OCNGS, but only included limited participation from select offsite emergency response organizations and associated evaluation by FEMA. The involvement of all required offsite emergency response organizations could not be completed as scheduled due to the impact of Hurricane Irene which passed through the State of New Jersey on August 28,2011.

This hurricane affected local governments and diverted resources in responding to the aftermath of the storm. As a result, by letter dated September 30, 2011 (ML112730283),

OCNGS requested a one-time exemption to reschedule until June 2012 those specific offsite aspects that were not completed and evaluated during the September 27, 2011, EP exercise.

The NRC subsequently granted this exemption as documented in a letter dated December 22, 2011 (ML113410302). The remaining offsite portions deferred from the September 2011 exercise were satisfactorily completed on June 12, 2012, as documented in a FEMA letter (Attachment 2). FEMA determined that the State and local preparedness is adequate to protect the health and safety of the public living in the vicinity of the OCNGS and will provide reasonable assurance that appropriate measures can be taken offsite in the event of a radiological emergency.

OCNGS made a good faith effort to comply with the requirements to conduct the full-participation, FEMA-evaluated, biennial EP exercise on October 8, 2013. An extensive amount of planning was performed, a challenging scenario was developed, and the submission of the exercise scenario was completed as required as documented in an August 1, 2013, letter from Exelon to the NRC.

FEMA has responded favorably to this deferral request and has agreed to postpone and reschedule the evaluation of the offsite emergency response organization elements until March 18,2014, as documented in a letter dated October 10, 2013 (Attachment 3). FEMA also provided notification of its acceptance to reschedule the exercise until March 2014 in a letter dated October 3, 2013 (Attachment 4). In addition, the New Jersey Office of Emergency Management (NJOEM) supports rescheduling the exercise until March 18, 2014, as documented in a letter dated October 9, 2013 (Attachment 5).

Exelon discussed with FEMA and the State of New Jersey a range of possible dates to conduct the OCNGS biennial exercise. Given the unknown duration of the government shutdown as well as pre-existing resource commitments by the various offsite agencies, it was agreed that March 2014 would be the best option.

Justification for the Exemption In accordance with 10 CFR 50.12(a)(1), the U.S. Nuclear Regulatory Commission (NRC) may grant exemptions from certain requirements of the 10 CFR 50 regulations that are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.

1. This exemption request is authorized by law:

In accordance with 10 CFR 50.12, the NRC may grant an exemption from the requirements of 10 CFR 50, if the exemption is authorized by law. The proposed exemption is authorized by law in that no other prohibition of law exists to preclude the activities which would be

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix Section IV.F.2.b and IV.F.2.c Page 4 of 21 authorized by the exemption. The proposed exemption will continue to serve the underlying purpose of the regulation. The underlying purposes for conducting a full-participation biennial EP exercise are to test the adequacy of emergency plans, to ensure that emergency response organization personnel are familiar with their duties, and to identify and correct weaknesses. The activities performed during an OCNGS off-year exercise conducted on July 10, 2012, along with a number of Out-ot-Sequence (OOS) drills that were conducted, demonstrate that these underlying purposes of conducting an exercise have been met.

2. This exemption request will not present an undue risk to the public health and safety:

Adequate emergency response capabilities have been maintained and demonstrated since the last OCNGS biennial exercise (September 27, 2011) through the performance of drill and exercises and OOS drills.

A. Onsite Exercises! Drills 2012 OCNGS Exercise ! Drill Schedule Dates Drill! Exercise 02115/12 Full Scale Drill - Drill and Exercise Performance (DEP) 04/25/12 Full Scale Drill - DEP 07/10/12 Full Scale Exercise - DEP 08/22/12 Full Scale Drill - DEP 2013 OCNGS Exercise I Drill Schedule Dates Drill I Exercise 02113/13 Full Scale Drill - DEP 07/10/13 Full Scale Drill - DEP 07/24/13 Full Scale Drill - DEP 09/12/13 Full Scale Exercise - DEP Summary of 2012 Drills and Exercises

1. On February 15, 2012, OCNGS successfully completed an EP full-scale integrated drill involving onsite participation trom the following:
  • Control RoomlSimulator (CRS)
  • Operational Support Center (OSG)
  • Emergency Operations Facility (EOF)
  • Joint Information Center (JIG)
  • Field Monitoring Teams (FMTs)

The overall performance during the drill by emergency response organization personnel was determined to be satisfactory. In addition, the drill also incorporated the Semi-Annual Health Physics Drill, which was successfully performed demonstrating satisfactory ability of the OSC to establish area contamination controls.

Drill and Exercise Performance (DEP) opportunities were determined to be satisfactory with eight of eight DEP opportunities successfully demonstrated. Performance is

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 5 of 21 evaluated as either satisfactory or unsatisfactory based on the overall ability to meet the applicable planning standards specified in NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (NUREG-0654IFEMA-REP-1). The actions taken by the OCNGS 1/

emergency response personnel during this drill were determined to be sufficient to protect the health, safety, and welfare of the public. Areas requiring improvement were entered into the Corrective Action Program (CAP) for further evaluation and disposition.

2. On April 25, 2012, OCNGS successfully completed an EP full-scale integrated drill involving onsite participation from the following:
  • FMTs The overall performance during the drill by emergency response organization personnel was determined to be satisfactory with seven of eight DEP opportunities successfully demonstrated. Performance is evaluated as either satisfactory or unsatisfactory based on the overall ability to meet the applicable planning standards specified in NUREG-0654. The actions taken by the OCNGS emergency response personnel during this drill were determined to be sufficient to protect the health, safety, and welfare of the public.

Areas requiring improvement were entered into CAP for further evaluation and disposition.

3. On July 10, 2012, OCNGS completed a full-scale Off-year exercise involving onsite and offsite participation from the following:

State of New Jersey

  • NJOEM
  • FMTs
  • Emergency News Center (ENG)

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix Section IV.F.2.b and IV.F.2.c Page 6 of 21 The overall performance during the exercise was determined to be satisfactory with seven of eight DEP opportunities successfully demonstrated. It was concluded that, had the events actually happened, the health, safety and welfare of the public would have been adequately protected. All Risk Significant Planning Standards (RSPS) and Non-Risk Significant Planning Standards (PS) were successfully demonstrated along with all of the overall exercise objectives. Performance is evaluated as either satisfactory or unsatisfactory based on the overall ability to meet the applicable planning standards specified in NUREG-0654. Areas requiring improvement were entered into CAP for further evaluation and disposition.

4. On August 22, 2012, OCNGS successfully completed an EP full-scale integrated drill involving onsite participation from the following:
  • FMTs The overall performance during the drill by emergency response organization personnel was determined to be satisfactory with 11 of 11 DEP opportunities successfully demonstrated. Performance is evaluated as either satisfactory or unsatisfactory based on the overall ability to meet the applicable planning standards specified in NUREG-0654. The actions taken by the OCNGS emergency response personnel during this drill were determined to be sufficient to protect the health, safety, and welfare of the public.

Areas requiring improvement were entered into CAP for further evaluation and disposition.

5. On December 5,2012, OCNGS, along with Toms River Community Medical Center, and Lanoka Harbor First Aid, successfully completed the annual Medical Drill. Participant performance was judged to be satisfactory. Performance is evaluated as either satisfactory or unsatisfactory based on the overall ability to meet the planning standards pursuant to NUREG-0654. Actions taken by the staff were sufficient to properly demonstrate proficiency for the protection of the health and safety of the public and employees.
6. On December 10, 2012, OCNGS successfully completed the annual Assembly and Accountability Drill. The performance during this drill was determined to be satisfactory.

Performance is evaluated as either satisfactory or unsatisfactory based on the overall ability to meet the planning standards pursuant to NUREG-0654.

Summary of 2013 Drills and Exercises

1. On February 13, 2013, OCNGS successfully completed an EP full-scale integrated drill involving onsite participation from the following:

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix Section IV.F.2.b and IV.F.2.c Page 7 of 21

  • FMTs The overall performance during the drill by emergency response organization personnel was determined to be satisfactory with eight of eight DEP opportunities successfully demonstrated. Performance is evaluated as either satisfactory or unsatisfactory based on the overall ability to meet the applicable planning standards specified in NUREG-0654. The actions taken by the OCNGS emergency response personnel during this drill were determined to be sufficient to protect the health, safety, and welfare of the public.

Areas requiring improvement were entered into CAP for further evaluation and disposition.

2. On April 23, 2013, OCNGS, along with Southern Ocean Medical Center and Lacey Emergency Medical Services (EMS) successfully completed the annual Medical Drill. In addition, a Semi-Annual Health Physics Drill was also successfully completed. The activities involved onsite and offsite participation from the following:

Onsite

  • Control Room
  • First Aid Team
  • Radiation Protection Offsite
  • Lacey EMS
  • Southern Ocean Medical Center The medical emergency scenario contained the elements of a First Aid and Medical Emergency Response drill and included the appropriate demonstration criteria.

Participant performance was judged to be satisfactory. Performance is evaluated as either satisfactory or unsatisfactory based on the overall ability to meet the planning standards pursuant to NUREG-0654. Actions taken by the staff were sufficient to properly demonstrate proficiency for the protection of the health and safety of the public and employees.

3. On July 10, 2013, and July 24, 2013, OCNGS successfully completed a series of EP integrated drills involving onsite participation from the following:
  • FMTs The overall performance during the drill by emergency response organization personnel was determined to be satisfactory with eight of eight DEP opportunities successfully

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 8 of 21 demonstrated during the July 10, 2013, exercise and four of four DEP opportunities successfully demonstrated during the July 24, 2013, exercise. Performance is evaluated as either satisfactory or unsatisfactory based on the overall ability to meet the applicable planning standards specified in NUREG~0654. The actions taken by the OCNGS emergency response personnel during this drill were determined to be sufficient to protect the health, safety, and welfare of the public. Areas requiring improvement were entered into CAP for further evaluation and disposition.

4. On September 12, 2013, OCNGS successfully completed an exercise involving onsite participation from the following:
  • JIC The overall performance during the drill by emergency response organization personnel was determined to be satisfactory with three of four DEP opportunities successfully demonstrated. Performance is evaluated as either satisfactory or unsatisfactory based on the overall ability to meet the applicable planning standards specified in NUREG~

0654. The actions taken by the OCNGS emergency response personnel during this drill were determined to be sufficient to protect the health, safety, and welfare of the public.

Areas requiring improvement were entered into CAP for further evaluation and disposition.

B. Onsite Focused Area Drills 2012 OCNGS Focused Area Drill Schedule Dates Drill 01/18/12 TSCI EOF 01125/12 02/08/12 These drills focused on:

02/29/12 or

  • Emergency Action Level (EAL) changes and 1Q12 Recovery 1 Termination
  • Review of lessons learned from recent drills (e.g.,

unsatisfactory demonstration criteria, objectives, improvement opportunities)

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 9 of 21 05/31/12 EOF I JIC I ENC 06/07/12 06/14/12 These drills focused on:

06/20/12 or

  • Lessons Learned from recent drills (e.g.,

2Q12 unsatisfactory demonstration criteria, objectives, improvement opportunities)

  • Communications - between EOF and JIC
  • Command & Control - facility briefings
  • Maintaining Status Boards and position logs
  • USing Web-EOC
  • CLASSIFICATIONS: Recognize, determine and recommend EAL Classifications to the Station Emergency Director (SED) based on information provided. Provide Peer check for SED.
  • PARS: Complete forms for Notifications and PARs accurately and timely
  • NOTIFICATIONS: Statel Local Communicator simulate notifications by reading forms to the Controller accurately and timely.
  • DAPAR performance
  • RELEASE IN PROGRESS determination performance
  • ENC: News Releases and Chronological Events Description Logs
  • JIC: Press Conference preparation and conduct with mock media 09/13/12 TSC/OSC 09/20/12 09/27/12 These drills focused on:

10/04/12 or

  • Lessons Learned from recent drills (unsatisfactory demonstration criteria, objectives, improvement 3Q12 opportunities, SAMG Implementation)
  • Recent plan or procedure changes (Activation process, Interim Filling of Minimum Staffing Positions & Dose Assessment (URI))
  • Focused Practice Sessions (communications, teamwork, briefings, status boards, classifications, notifications)
  • Focused Performance evaluations (CDAM determinations and State and Local Notifications)

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 10 of 21 2013 OCNGS Focused Area Drill Schedule Date Drill 01/16/13 TSCI EOF 01124/13 01/31/13 These drills focused on:

02/07/13 or

  • 2012 TSC and EOF lessons learned for 1013 performance improvement
  • EOFITSC/FMT roles and responsibilities
  • Facility activation process
  • Command and control turnover
  • Station priorities
  • Dose-based PARS 04/04113 EOF 1 JIC 1 ENC 04/11/13 04/18/13 These drills focused on:

04/25/13 or

  • Lessons learned from recent drills (e.g.,

2013 unsatisfactory demonstration criteria, objectives, improvement opportunities)

  • ERF activation and command and control turnover process
  • News releases and event chronologies
  • Press Conferences 10/23/13 TSC/OSC 10130/13 11/06/13 These upcoming drills will focus on:

11/13/13 or Lessons Learned from recent drills (e.g., unsatisfactory 4013 demonstration criteria, objectives, improvement opportunities)

ERF activation and Command and Control turnover process (DEP evaluated)

CLASSIFICATIONS: Recognize, determine and recommend EAL classifications to the SED based on information provided. Provide Peer check for SED.

NOTIFICATIONS: Statel Local Communicator will simulate notifications by reading forms to the Controller accurately and timely PARS: Complete forms for notifications and PARs accurately and timely

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix Section IV.F.2.b and IV.F.2.c Page 11 of 21 C. Offsite Exercises I Drills As noted above, FEMA and NJOEM have agreed to postpone and reschedule the OCNGS full-participation biennial exercise until March 18, 2014. FEMA and NJOEM have successfully conducted and completed all OOS drills with the exception of Medical Services and Mass Care. FEMA and NJOEM will attempt to complete these demonstrations when Federal funding for FEMA travel is restored. The list and table below provide details of the facilities and functions rescheduled until March 2014.

Facilities Rescheduling Their Participation to March 2014

  • Ocean County EOC
  • Barnegat Light Borough
  • Barnegat Township
  • Beachwood Borough
  • Berkeley Township
  • Toms River (Dover) Township
  • Harvey Cedars Borough
  • Island Heights Borough
  • Lacey Township
  • Long Beach Township
  • Ocean Gate Borough
  • Ocean Township
  • Pine Beach Borough
  • Seaside Park Borough
  • Ship Bottom Borough
  • South Toms River Borough
  • Stafford Township
  • Surf City Borough List of Functions Rescheduled to March 2014 Criterion EP functions evaluated at the State, County, and Local Offsite (FEMA Program Manual Response Organizations (OROs)

Radiological Emergency Preparedness) 1 I yency Operations Management 1.a.1 Notification and Mobilization 1.c.1 Direction and Control 1.d.1 Communications Equipment 1.e.1 Equipment and supplies to Support Operations 2 Protective Action Decision-Making 2.a.1 Emergency Worker Exposure 2.b.1 Rad Assessment PARS 2.b.2 Rad Assessment PADs for General Public

Request tor Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 12 of 21 2.c.1 Protective Action decisions for DAFN Populations 3 Protective Action Implementation 3.a.1 Emergency Worker Exposure 3.b.1 KI Decision 3.c.1 PADs for DAFN Populations 3.c.2 r Schools 3.d.1 Traffic and Access Control 3.d.2 Impediments to Evacuation Identified and Resolved 4 Field Measurements and Analysis 4.a.1 Plume Phase Measurement and Analysis 4.a.2 Plume Phase Field Measurement and Analysis Management 4.a.3 Plume Phase Field Measurement and Analysis Procedures 5 Emergency Notification and Public Information 5.a.1 Activation of Prompt Alert and Notification 5.b.1 Emergency Information and instructions for the Public and Media 6 Support Operations/Facilities 6.a.1 Monitoring/Decontamination/Registration of Evacuees 6.b.1 Monitoring/Decontamination of Emergency Workers 6.c.1 ~rary Care of Evacuees 6.d.1 d Treatment of Contaminated Individuals The NJOEM and the NJBNE successfully exercised the State Radiological Emergency Response Plan (RERP) and Annex B for OCNGS on September 27,2011, which was the last scheduled full-participation biennial EP exercise. During the interim year, the NJOEM and NJBNE successfully exercised the State RERP and Annex A for Salem/Hope Creek Nuclear Generating Stations on May 22, 2012. Even though this did not involve the local county and boroughs/municipalities local to OCNGS, the NJOEM and NJBNE did participate and were evaluated during this exercise. The NJOEM functioned as a "Sim Cell" for the successful exercise by Ocean County and the municipalities within the 10-mile Emergency Planning Zone (EPZ) of Annex B on June 12,2012. As noted previously, Attachment 2 contains more information from FEMA concerning the evaluation of the September 27, 2011, and June 12, 2012, exercises. Caption In addition to the evaluations described in FEMA after-action improvement plans for the September 2011 and June 2012 exercises, the following drills have been successfully conducted in 2013.

Date Drill/ Meeting 02/15/12 I \",ludllerly Drill with Exelon OCNGS 04/25/12 Quarterly Drill with Exelon OCNGS 08/22/12 Quarterly Drill with Exelon OCNGS 12/05/12 Quarterly Drill with Exelon OCNGS 02/13/13 Quarterly Drill with Exelon OCNGS 05/17/13 Emergency Worker Decontamination Exercise at Bayville Fire Company 07/30/13 Ocean Lakewood High Reception Center Demonstration 09/12113 Practice Exercise for FEMA Exelon OCNGS

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV,F.2.b and IV. Page 13 of 21 D. Onsite Training 2012 OCNGS EP Training Date Training 05/01/12 EOF/JIC/ENC 05102/12 FMT 05/03/12 TSC/OSC 05108/12 EOF/JIC/ENC

~SC 05109/12 05/10/12 05/15/12 EOF/JIC/ENC 05116/12 FMT 05/17/12 TSC/OSC 05122112 EOF/JIC/ENC 05123/12 FMT 05/24/12 TSC/OSC 2013 OCNGS EP Training Date Training 04/30/13 EOF/JIC/ENC 05101/13 FMT 05/02/13 TSC/OSC 05107/13 EOF/JIC/ENC 05108/13 FMT 05/09/13 TSC/OSC 05114/13 EOF/JIC/ENC 05115/13 FMT 05/16/13 TSC/OSC 05121113 EOF/JIC/ENC 05122113 FMT 05/23/13 TSC/OSC The 2012 and 2013 training provided for the onsite emergency response personnel consists of covering the following EP aspects and objectives:

  • Review Emergency Response Organization (ERO) fundamentals
  • Review Emergency Response Facility (ERF) augmentation
  • Review Exelon Emergency Classifications
  • Review computer applications
  • Review communication systems
  • Review command and control
  • Review Emergency Action Levels (EALs)
  • Review Termination and Recovery
  • Identify results of NRC Bulletin 2005-02 (B.5,b) implementation This training provides assurance that OCNGS has the capability to: 1) protect the health and safety of the general public in the communities around OCNGS and the

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 14 of 21 personnel who work at the plant; 2) limit damage to facilities, equipment, and property; and 3) restore the station following an emergency. Onsite emergency response personnel are required to take and pass a position-specific examination at the completion of the training.

E. Offsite Training In addition to the exercisesldrills performed since the last biennial exercise at the OCNGS, the following training was accomplished by the State, County, and municipal Offices of Emergency Management.

Date Training Po2/02/12 Emergency Worker Self Protection Barnegat PO Emergency Worker Self Protection Ocean Ride 01/26/12 Emergency Worker Self Protection South Toms River EMS & Scouts 01/27/12 Emergency Worker Self Protection (Train-The-Trainer) Toms River OEM, OC OEM, Lakewood OEM, OC Sheriff, Barnegat Light OEM, Jackson OEM & PO, Ocean Gate OEM 01/27/1~ergency Worker Self Protection Beachwood Fire, Beachwood FAS, South ms River PO 01/31/12 Emergency Worker Self Protection Forked River Fire 02/22/12 Emergency Worker Self Protection Jackson VFO #1, Howell FAS 02/24/12 Emergency Worker Self Protection Manitou Park Fire, South Toms River FAS 02/24/12 Emergency Worker Self Protection (Train-The-Trainer) South Toms River CERT, Manitou Park FO, NJSP Troop C, Lacey PO, County PSTs, Beachwood OEM, Lakewood OEM, South Toms River O,EM, Point Pleasant Beach PO, Stafford PO, Brick PO, Ocean Gate OEM, Beach haven OEM, Barnegat OEM, Harvey Cedars OEM, CART 03/01/12 Emergency Worker Self Protection Lacey PO 03/05/12 Emergency Worker Self Protection TRA Chestnut St 03/13/12 Emergency Worker Self Protection Lacey PO, Lacey OEM 03/13/12 Emergency Worker Self Protection Parkertown Fire, Parkertown FAS,West Tuckerton Fire, MystiC Island Fire 03/15/12 FEMA Program Manual Review Egg Harbor OEM, Lakewood OEM, Manchester OEM, Stafford OEM, Toms River OEM, Harvey Cedars OEM, Beachwood OEM, Long Beach OEM, OC OEM, Ocean Gate OEM, Brick OEM, Ocean Twp OEM, Barnegat Light OEM, Jackson OEM & PO, Surf City OEM, Ship Bottom OEM, Island Heights OEM, South Toms River OEM, Pine Beach OEM, CART 03/18/12 Reception Center Managers Course Manchester OEM, Cumberland OEM, Salem OEM, Toms River OEM, BERT, Jackson PO, Pine Beach Fire, CART, Ocean County Sheriff=s OEM 03/02/12 Emergency Worker Self Protection Brick CERT 03/22/12 Emergency Worker Self Protection South Toms River OEM 03/22/12 Emergency Worker Self Protection Great Bay EMS 03/22112 Emergency Worker Self Protection Brick Fire 03/23/12 Emergency Worker Self Protection South Toms River Council, Central Regional

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 15 of 21 Transportation 03/23/12 Emergency Worker Self Protection Little Egg Harbor Public Works 03/23/12 Emergency Worker Self Protection County Health 03/29/12 Emergency Worker Self Protection Jackson Firect District 3 03/30/12 EOC Operations Course OC OEM, Surf City OEM, Ocean Twp OEM, Toms River OEM, Barnegat Light OEM, Brick OEM, Pine Beach OEM, Jackson OEM & PO, Lanoka Harbor FD, Ocean Gate OEM, Berkeley OEM & PO, Stafford OEM, Lacey PO, Long Beach OEM, Monmouth Co Health, Beachwood OEM, Barnegat OEM 04/02/12 Emergency Worker Self Protection Ocean Gate FAS 04/02/12 Emergency Worker Self Protection OC Road Dept 04/04/12 Emergency Worker Self Protection OC Road Dept 04/05/12 Emergency Worker Self Protection OC Road Dept 04/17/12 Emergency Worker Self Protection Little Egg Harbor PO, CERT 04/17/12 Emergency Worker Self Protection Cassville FD 04/17/12 Emergency Worker Self Protection Long Beach: OEM, PO, Public Works, Twp Administration 04/18/12 Emergency Worker Self Protection Long Beach: Water and Sewer, Finance, Public Works, PO 04/18/12 Emergency Worker Self Protection East Dover FAS 04/18/12 Emergency Worker Self Protection RACES 04/30/12 Emergency Worker Self Protection Lanoka Harbor Fire 04/30/12 Emergency Worker Self Protection High Point Fire 04/30/12 Emergency Worker Self Protection Ocean gate FAS, Lacey FAS 05/04/12 Emergency Worker Self Protection Harvey Cedars: OEM, PO, Administration, Public Works 05/10/12 Emergency Worker Self Protection Eagleswood FD 05/10/12 Emergency Worker Self Protection Long Beach Twp PO 05/10/12 Emergency Worker Self Protection OC Sheriffs Dept, Health, Transportation, CART, ARC, Social Services, EMS, Engineering 05/16/12 Emergency Worker Self Protection Toms River Police Auxiliary 05/21/12 ilmergency Worker Self Protection Emergency Worker Self Protection Ocean ate Fire 05/24/12 Emergency Worker Self Protection Beach Haven Fire OS/24/12 Emergency Worker Self Protection Surf City PO 05/25/12 Emergency Worker Self Protection Bayville FD 06/01/12 EOC Operations Course Beachwood OEM, OC OEM, Berkeley OEM, South Toms River OEM, Monmouth Co Health, Toms River OEM, Ship Bottom OEM, Harvey Cedars OEM, Ocean Gate OEM, Ocean Twp OEM, Long Beach OEM, OC Health 06/05/12 Emergency Worker Self Protection Berkeley Twp Transportation 06/07/12 Emergency Worker Self Protection Berkeley: Public Works, Sanitation, PO, Parks, South Toms River Roads 06/07/12 Emergency Worker Self Protection Ocean Gate OEM, Borough Officials 06/08/12 Emergency Worker Self Protection Salvation Army, County PIO, ARC 07/13/12 Emergency Worker Self Protection Jackson OEM, Harvey Cedars OEM, Middlesex Health, STR OEM, Monmouth Health

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 160f21 07/17/12 Emergency Worker Self Protection Jackson CERT, Jackson FAS 07/18/12 Reception Center Managers Course Jackson: CERT, PO, OEM, EMS, Whitesville FD, Jackson Mills FD 07/18112 Emergency Worker Self Protection Jackson: OEM, CERT 07/19/12 ~ePtion Center Managers Course Jackson: CERT, PO, OEM, EMS, itesville FD, Jackson Mills FD, OC Health 07/23/12 Reception Center Managers Course Jackson: CERT, PO, OEM, EMS, Whitesville FD, Jackson Mills FD, OC Health 07/24/12 Reception Center Managers Course Jackson: CERT, PO, OEM, EMS, Whitesville FD, Jackson Mills FD, OC Health 07/24/12 Emergency Worker Self Protection Jackson: EMS, CERT 07/25/12 I Emergency Worker Self Protection Jackson PO 07/26/12 Emergency Worker Self Protection Jackson PO 07/27/12 Emergency Worker Self Protection Jackson PO 07/27/12 Emergency Worker Self Protection Lanoka Harbor EMS 08/03/12 Emergency Worker Self Protection Jackson PO

~8/03/12 Emergency Worker Self Protection Island Heights PO, Fire, FAS Emergency Worker Self Protection Ocean County Sheriffs Dept 08/16/12 Emergency Worker Self Protection Pine Beach: OEM, FD, Public Works, PO 08/16/12 Emergency Worker Self Protection School Drivers 08/17/12 Emergency Worker Self Protection Seaside Park PO 08/18/12 Emergency Worker Self Protection Pine Beach Fire 08/25/12 Emergency Worker Self Protection Point Pleasant Borough FAS 09/12/12 Emergency Worker Self Protection Ocean County OEM 09/12/12 Emergency Worker Self Protection Lakewood PO 09/14/12 Emergency Worker Self Protection Lakewood PO 09/17/12 Emergency Worker Self Protection Lakewood PO 09/18/12 Emergency Worker Self Protection Lakewood PO 09/19/12 Emergency Worker Self Protection Lakewood PO 09/20/12 Emergency Worker Self Protection Lakewood PO 09/21/12 Emergency Worker Self Protection Lakewood PO 09/18/12 Emergency Worker Decon Center Manager Course High Point FD, Barnegat Light FD, Surf City FD, Harvey Cedars PO, Barnegat Light EMS, Barnegat Light OEM 09/20/12 Emergency Worker Decon Center Manager Course High Point FD, Barnegat Light FD, Surf City FD, Harvey Cedars PO, Barnegat Light EMS, Barnegat Light OEM, Long Beach PO 09/25/12 Emergency Worker Decon Center Manager Course High Point FD, Barnegat Liqht FD, Surf City FD, Harvey Cedars PO, Barneqat Light EMS, Long Beach PO 10/10/12 Emerqency Worker Self Protection Lakehurst OEM, Public Works, Fire, PO 10/11/12 Emerqency Worker Self Protection Lacey EMS 10/22/12 Medical Services MS-1Waretown FAS 10/25/12 Medical Services MS-1Waretown FAS 12/11/12 Emergency Worker Self Protection Lakewood PO

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 17 of 21 Date Training 01/14/13 Emergency Worker Self Protection CERT 01/25/13 Emergency Worker Self Protection (Train-The-Trainer) - OC OEM, Lakewood OEM-PO-EMS, OC Sheriff, Manchester OEM, Surf City OEM-PO, Jackson OEM

& PO, Stafford OEM, BERT Hazmat, Lanoka Harbor EMS, Beachwood OEM, OC Vehicle Services, Island Heights OEM, Berkeley OEM-PO Harvey Cedars OEM, OC Health Dept., Exelon 02/08/13 Emergency Worker Self Protection (Train-The-Trainer) - Pine Beach OEM, BERT Hazmat, FEMA R2, Exelon, STR OEM, Lakehurst PO, Jackson OEM-PO, Harvey Cedars OEM, Seaside Park OEM-PO, Ocean TWP OEM-PO, OC OEM, Ship Bottom OEM-PO, Lacey TWP OEM-PO, 02/12/13 Emergency Worker Self Protection - Parkertown COP/CERT, Parkertown Fire Station 70, New Gretna Fire Station 421, EMS Squad 85, Mystic Island Fire Station 72, West Tuckerton Station 71, 02/22/13 ency Worker Self Protection - Manitou Park Fire, South Toms River OEM/CERT/Fire/EMS/PD 02127/13 Emergency Worker Self Protection - Whitesville Fire (Jackson) 02/28/13 Emergency Worker Self Protection - Jackson Fire Districts 1,2,3&4/0EM 03/05113 Emergency Worker Self Protection - OC Road Dept.

03/06/13 Emergency Worker Self Protection - OC Road Dept 03/08/13 Reception Center Managers Course Bayville FAS, Manchester OEM-Fire, Monmouth Co. Hazmat, OC OEM, Lakewood OEM-PO-EMS, Toms River OEM, Howell OEM, Harvey Cedars OEM-PO, Jackson OEM-PO, Salem County CERT-OEM 03/10/13 Emergency Worker Self Protection - Lakewood Fire 03/13/13 Emergency Worker Self Protection Lacey PO 03/14/13 Emergency Worker Self Protection - Central Regional Schools, STR 03/19/13 Emergency Worker Self Protection - Lacey PO 03/19/13 Emergency Worker Self Protection - Lakewood FAS 03/21/13 Emergency Worker Self Protection - Silverton EMS 03/22/13 Emergency Worker Self Protection - Lacey PO 03/24/1ffimergency Worker Self Protection - Lakewood FD 03/27/13 Emergency Worker Self Protection - Beachwood FAS 04/04/13 Emergency Worker Self Protection - Pleasant Plains FD 04/05/13 Emergency Worker Self Protection - Lacey PO 04/11/13 Emergency Worker Self Protection - Pine Beach Fire Co., OEM 04/17/13 Emergency Worker Self Protection - RACES 04/18/13 Emergency Worker Self Protection - Lacey PO 04/22/13 Emergency Worker Self Protection - Lanoka Harbor Fire Dept 04/29/13 Emergency Worker Self Protection - High Point Fire Co.

04/29/13 Emergency Worker Self Protection - Harvey Cedars PD-PW-OEM-Boro 05/01/13 Emergency Worker Self Protection - OC OEM-CIU-FM, Baker 05/01/13 Emergency Worker Self Protection - OC CART-Transportation-UA-HS-SWM-OEM-EMS-CIU-VS-HD-RD-Senior Services, DEP Fire Coord., Baker, Am Red Cross, Salvation Army, Ocean Ride, Verizon 05/04/13 Emergency Worker Self Protection - Pt Pleasant Beach PO

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 18 of 21 05/05/13 Emergency Worker Self Protection - Pt Pleasant Beach PO 05/21/13 Emergency Worker Self Protection - Beachwood OEM 05/22/13 Emergency Worker Self Protection Lacey PO 06/06/13 Emergency Worker Self Protection OC Sheriff's Office 06/10/13 Emergency Worker Self Protection Surf City PO-OEM-FO 07/01/13 Emergency Worker Self Protection - Surf City OEM-Fire-EMS-PO 07/09/13 Emergency Worker Self Protection - Lakewood OEM-CERT-ITM-Chaplin-PO-PW 07/16/13 Emergency Worker Self Protection OC Health Dept, ARC 08/07/13 Emergency Worker Self Protection ARC, Seaside Heights OEM 08/09/13 EOC Operations Course OC OEM, ARC, Monmouth Cty Hazmat, Exelon, Lakehurst OEM, Stafford OEM, Toms River OEM, NJSP OEM, STR OEM, Pine Beach OEM-PO, Seaside Heights OEM, Berkeley OEM-PO, FEMA R2, Beachwood OEM, Ocean Twp. OEM-PO, 08/09/13 Emergency Worker Self Protection Island Heights Fire Oept.-PO-Boro-_, _

OEM 08/09/13 Emergency Worker Self Protection -Island Heights FAS 08/27/13 Emergency Worker Self Protection - NJSP Tuckerton 09/09/13 Emergency Worker Self Protection - Seaside Park Community Watch 09/13/13 EOC Operations Course - SEOC/NJSP, Exelon EP, Ocean Gate OEM, Surf City OEM, Beach Haven OEM, Ship Bottom OEM, OCSO OEM, Barnegat Light OEM, Long Beach Twp OEM-PO, 09/17/13 Emergency Worker Self Protection (Train-The-Trainer) - OCSC OEM, Ship Bottom OEM, AMR, Tuckerton OEM, Barnegat Light OEM, Ocean Air Support Squadron 09/19/13 Emergency Worker Self Protection - Ocean Air Support Squadron 09/24/13 Emergency Worker Self Protection - NJSP Barnegat Bay 09/25/13 Emergency Worker Self Protection - Surf City VFC 09/25/13 Emergency Worker Self Protection - OC CART, STR OEM Emergency Worker Self Protection OCCART 09/30/13 Emergency Worker Self Protection - Barnegat Light OEM-FAS-VFC-PO 10102/13 EOC Operations Tabletop Exercise - Ocean Gate OEM 10104/13 Emergency Worker Self Protection - OC Prosecutors Office

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix E,Section IV.F.2.b and IV.F.2.c Page 19 of 21 EW Ocean RERP Decon County Training Ocean and EOC Ocean Recept County Reception Practice RERP County as EW EOC Center and Courses, of 09/24/13 EW Self EW Decon EOC Exercise Drill Graded Exercises Protection TIT Center OPS Meetings (4 nights) Exercise and Drills January 41 24 3 February 261 16 8 March 274 28 11 April 121 7 May 139 40 8 June 25 2 July 117 92 4 AUQust 61 32 4 September 154 11 20 26 65 11 October November December Total Number of Individuals 1193 51 28 52 26 132 65 1547 Total Courses 48 3 1 2 1 2 1 58 Actual Events On October 29 and 30, 2012, OCNGS was impacted by Super Storm Sandy resulting in the plant making an ALERT declaration as a result of the affects of the storm.

During response to Super Storm Sandy, the NJOEM and the Ocean County and municipal OEMs were activated per their emergency plan to protect the health and safety of the public.

On November 27, 2012, the NRC completed a special inspection at OCNGS, which was conducted to evaluate the EP program performance and organizational decision-making associated with OCNGS's response to the storm. This inspection was conducted to expand

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix Section IV.F.2.b and IV.F.2.c Page 20 of 21 on the inspection activities performed by the Resident Inspector and Regional Inspectors who provided the real-time storm response coverage. The decision to conduct this special inspection was based on deterministic-only criteria involving EP program implementation during the actual event; specifically, initial concerns that OCNGS may not have met the planning standards associated with the classification and notification of an event. The inspection focused on reviewing selected procedures and records, observing activities, and interviewing personnel. As a result of the inspection, no NRC-identified or self-revealing findings were identified. The NRC concluded that OCNGS's performance was acceptable and that emergency action level declarations were timely. The results of the inspection are documented in NRC inspection report dated January 10, 2013 (ML 1301 OA470).

Also included in Attachment 6, is a FEMA letter dated May 9, 2013, addressed to NJOEM concerning an Annual Letter of Certification (ALC) for 2012. FEMA acknowledges that after reviewing all supporting documentation, FEMA determined that the State of New Jersey was compliant with all of the requirements in the Radiological Emergency Preparedness (REP)

Program for 2012. FEMA also recognized the efforts of the New Jersey Radiological Emergency Response Planning and Technical Unit for its dedication to assuring radiological response capabilities during the impacts of Super Storm Sandy.

3. This exemption request is consistent with the common defense and security:

The common defense and security are not affected by this exemption request.

This exemption requests NRC approval to extend the schedule for performing the full-participation biennial EP exercise until March 2014, as a result of impact of the Federal government shutdown.

Granting this exemption will maintain focus on nuclear safety and security; therefore, it is ultimately in the interest of the common defense and security. Pursuant to 10 CFR 50.12(a)(2), the NRC will consider granting an exemption from the regulation if special circumstances are present. This exemption request meets this requirement since special circumstances are present as a result of the Federal government shutdown.

Additionally, the exemption would provide only temporary relief from the 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c requirements. The onsite and offsite functions will be evaluated during the rescheduled exercise scheduled for March 2014.

Environmental Assessment If the requested exemption is approved by the NRC, the OCNGS 2013 full-participation FEMA-evaluated biennial EP exercise would not have been conducted as originally scheduled on October 8, 2013. Whether or not these functions were conducted on this date would not have an effect on the environment since any outdoor activity during an exercise is limited to minimal use of roads and highways. The proposed action would not significantly increase the probability or consequences of an accident, change the types or quantities of radiological effluents that may be released offsite, or result in a significant increase in public or occupational radiation exposure since there would be no change to facility operations that could create a new accident or affect a previously analyzed accident or release path.

Request for Exemption Related to 10 CFR 50, Attachment 1 Appendix Section IV.F.2.b and IV.F.2.c Page 21 of 21 Since the proposed action would not have any adverse environmental effects, there are no alternatives available for reducing or avoiding adverse environmental effects. With regard to non~radiological impacts, no changes would be made to non~radiological plant effluents or activities that would adversely affect the environment Therefore, no significant non-radiological impacts would be associated with the proposed action.

There are no federal permits, licenses, approvals or other entitlements which must be obtained in connection with the proposed action. The proposed action is not subject to any environmental quality standards or requirements imposed by Federal, State, regional, or local agencies having responsibility for environmental protection.

Conclusion Based on the previously discussed information, a one-time exemption is requested from the requirements of Sections IV.F.2.b and IV.F.2.c of Appendix E to 10 CFR 50 to postpone the full-participation, FEMA-evaluated, biennial EP exercise as identified above until March 18, 2014, at OCNGS. This requested exemption is authorized by law, will not present an undue risk to the public health and safety, is consistent with the common defense and security, and special circumstances are present as set forth in 10 CFR 50.12(a)(2).

ATTACHMENT 2 Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Exemption Letter from Federal Emergency Management Agency to New Jersey Emergency Management Section, dated November 16, 2012 (Reference - FEMA Evaluation of September 27,2011, and June 12,2012, Exercises)

I

)

U.S. Department or Homeland Security Region Il

) Jacob K. lavits Fecieral Office Building 26 Federal Plaza, Room 1311 NewYo!'k. NY 10278-0002 FEMA November 16,2012 Captain Daniel Mitten Commanding Officer Emergency Management Section New Jersey State Police P.O. Box 7068 West Trenton, NJ 08628-0068

Dear Captain Mitten,

Enclosed please find a copy of the Final After Action Reportllmprovement Plan for the Limited Scale Exercise for the 10-Mile Emergency Planning Zone (EPZ) around the Oyster Creek Nuclear Generating Station (NGS) held on September 27, 2011. On August 29, 2011, your oUice requested permission to postpone the full-participation REP exercise due to the widespread devastation and flooding experienced throughout New Jersey as a result of Hurricane Irene and Tropical Storm Lee. As you know, these two storms required the Ocean County Otnce of Emergency Management and numerous State departments and agencies to make significant resource commitments to recover from this Presidentially Declared Disaster. We granted the request on August 30, 2011.

Subsequently FEMA R.Il, NRC Rl, the State of New Jersey and Exelon Corporation agreed to conduct a limited scale federally evaluated exercise in September 2011, with a makeup exercise for the COurIty and local risk jurisdictions that was held on June 12, 2012. The After Action Report for the makeup exercise will be provided under separate cover. Out of sequence demonstrations associated with this exercise cycle were evaluated as previously scheduled, and they are included in the report. .

The State of New Jersey, including the Bureau of Nuclear Engineering, Department of Environmental Conservation successfully demonstrated the capabilities to implement their off-site radiological emergency response plans and procedures, based on the evaluation of this exercise by the FEMA R. II Regional Assistance Committee and a team of Federal evaluators. Three new Areas Requiring Corrective Actions (ARCAs) were assessed. One prior state-level ARCA identified at the 2010 Salem-Hope Creek Exercise was resolved.

www.dhs.gov*PH; (212)680*3600

Therefore, we find that State and local preparedness is adequate to protect the health and safety of the public living in the vicinity of the Oyster Creek NOS and will provide reasonable assurance that appropriate measures can be taken offsite in the event of a radiological emergency.

If you have any questions regarding this matter, please contact Rebecca Thomson, Chair of the R. II Regional Assistance Committee at (2~2) 680-8509.

Sincerely yours, C>{jM/~

Lynn Canton Regional Administrator Enclosure

ATTACHMENT 3 Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Exemption Letter from Federal Emergency Management Agency to New Jersey Deputy Superintendent Homeland Security, State Police Division Headquarters, dated October 10, 2013 (Reference - Deferral of 2013 OCNGS Full-Participation Biennial EP Exercise)

FEMA cc:

ATTACHMENT 4 Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Exemption Letter from Federal Emergency Management Agency to New Jersey Deputy Superintendent Homeland Security, State Police Division Headquarters, dated October 3, 2013 (Reference Deferral of 2013 OCNGS Full-Participation Biennial EP Exercise)

F MA ATTACHMENT 5 Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Exemption Letter from New Jersey Office of Emergency Management to Exelon Emergency Preparedness Manager - Mid-Atlantic, dated October 9, 2013 (Reference - Deferral of 2013 OCNGS Full-Participation Biennial EP Exercise)

~tate o£ ~ efu JJerse!J Ot'f'"ICfOFTIIE ArrORNEY GENERAl.

CIIRIS CIIRISTIE DEI'ARTMENTOF LAW AND PUBLIC SAFETY JOliN J, HOFFMAN

(,'over"or DIVISION OF STATE POLICE AClillg AI/orney (f(!//(!rt/I POS! O~HCE l3<1x 706M KIM GUADAGNO W"ST TIIE:<O,OS NJ OR628*0Q611 COLONEL JOSEPti R. FUENTES 1./, C;ol'{!mor (609) !!82*2000 S',!'erintenth'lIl October 9,2013 Mr. Vincent Cwietneiwicz Emergency Preparedness Manager - Mid-Atlantic Exelon Corporation 200 Exelon Way Kennett Square, Pennsylvania 19352

Dear Mr. Cwietneiwicz:

The New Jersey Office of Emergency Management (NJOEM) has determined that Tuesday, March 18, 2014, is acceptable for the rescheduling of the FEMA-Evaluated Oyster Creek Nuclear Generating Station Exercise. The Exercise was originally scheduled for Tuesday, October 8,2013, but postponed due to the Federal Government shutdown. The New Jersey Bureau of Nuclear Engineering is also in agreement with the March 18, 2014 date.

If you have any questions concerning the exercise, please contact Jon Christiansen, Unit Head, RERP&T Unit, at (609) 963-6900, extension 6725.

Sincerely,

~(~

FOR COLONEL JOSEPH R. FUENTES SUPERINTENDENT Patrick J. Cal1ahan, Acting Major Commanding Officer Emergency Management Section PJC/JLC:law "An Internar'"nully Accredited AKenq'"

New Jersey 1.\' tin fqual Opportunity Emp/oyer Prinh-u (HI RC:(")'r/"d PeI/k'" "lUI Req'Cwhlt'

ATTACHMENT 6 Oyster Creek Nuclear Generating Station Docket No. 50-219 Request for Exemption Letter from Federal Emergency Management Agency to Commanding Officer, New Jersey Emergency Management Section, dated May 9, 2013 (Reference - Annual Letter of Certification)

U.S. Department of Homeland Security Region 1I Jacob K. Javits Federal Office Building 26 Federal Plaza, Room 1311 New York. NY 10278*0002 FEIVIA May 9,2013 Major Daniel Mitten Commanding Officer Emergency Management Section State of New Jersey .

Division of State Police PO Box 7068 West Trenton, NJ 08628-0068

Dear Major Mitten,

This is to respond to your Annual Letter of Certification (ALC) submitted with supporting documentation as prescribed in "NUREG-0654/FEMA REP-l and 44 CFR 350 Periodic Requirements." After reviewing all supporting documentation, we have detennined that the State of New Jersey was compliant with all of the requirements in the Radiological Emergency Preparedness (REP) Program for year 2012.

We understand the programmatic detail necessary to achieve the level of quality as provided in the ACL 2012 submission. The past year has seen many changes and challenges affecting our organizations. It is important to also recognize the efforts ofthe Radiological Emergency Response Planning and Technical Unit for its dedication to assuring radiological response capabilities during the impacts of Hurricane Sandy.

If there are any questions please do not hesitate to contact me at 212-680-8509, or Bill Cullen at 212-680-8505.

Sincerely Yours,

~~~

Rj,-

Rebecca S. Thomson RAC Chair and Technology Hazards Branch Chief Cc: Jon Christiansen, NJ OEM, REP Program Jerry Renner, NJ OEM, REP Program Allen Smith, NJ OEM, REP Program www.dhs.gov*PH: (212)680-3600

PART IV PROGRAM ADMINISTRATION

3. ANNUAL LETTER OF CERTIFICATION (ALC) REVIEW GUIDE

Purpose:

To provide guidance for review and evaluation of the Annual Letter of Certification (ALC) submitted by the States for compliance with periodic requirements.

Scope: Requirement:

The State ALC is reviewed to determine ./ 44 CFR part 350 whether all information/documentation is ./ NUREG-0654IFEMA-REP-l Planning Standard included pursuant to laws and regulations and A. 24-Hour Staffing Capability the Federal Emergency Management Agency G. Public Education and fnformation (FEMA) Radiological Emergency Preparedness H. Emergency Facilities and Equipment (REP) Program Manual. Information contained N. Exercises and Drills in the ALC is compared with the offsite O. Radiological Emergency Response Training response organi:l~tions (ORO) plans/procedures P. Responsibility for the Planning Effort and the Alert and Notification System (ANS) ./ FEMA-REP~ to design reports for consistency and accuracy. ./ FEMA REP Program Manual

-" r:;c~' :'\:~F:__ ;F: " ~ '_~'<j.'. : '. :'-1':> :'~P .;\:" r,,',,:;/.J ::*."- 4> *~-"I,..N,<- - --'t-~:!'-',,"7:f:;--~' -:;-A-;'t;~;-,7~;;~::~,rfo;";'t2:,

Con!i~,t~1I1~(hJ~;'~Lgll1c:lii~~s;\t~~:~oJ!9"\'\1ng:!t~~:);,~O~\:~:;O'f' Update of Plans/Procedures and Letters of Agreement Yes No NtA

1. A statement that ORO plans/procedures and Letters of Agreement (LOAs) have been reviewed for accuracy and completeness of information, and appropriate changes made, Updated LOAs and x

plan/procedure amendments must be submitted if not received previously.

Public Education and Information

1. A statement that annual dissemination of information to the pUblic was performed, and that the information includes how the public will be notified and what their actions should be in an emergency. This may be accomplished by, but not necessarily limited to, annual publications, periodic information in utility bills, and information in telephone books. (NlJREG-0654IFEMA-REP*

t, Evaluation Criteria G, 1 and G.2)

This statement must include the: Yes No N/A

3. Dates of dissemination x
b. Means of dissemination X
c. Identification of recipients X
d. Copies of all public information materials X REP Program Manual Page IV-52 April 2012 I I

PART IV PROGRAM ADMINISTRATION

2. A statement that emergency information was disseminated to locations frequented by transient populations in the emergency planning zone (EPZ), including (if applicable) hotels, motels, gas stations, phone booths, parks, marinas, boats, and other recreational areas. This may be accomplished by, but need not be limited to, decals, posters, or brochures/pamphlets. (NUREG-0654IFEMA-REP~

1, Evaluation Criteria G,I and G.2)

This statement must include: Yes No N/A

a. Dates of dissemination X
b. Means of dissemination X
c. Identification of locations where information was distributed or posted X
d. Copies of all public information materials X
e. Organizations responsible for distribution I X
3. A statement (if applicable) that yearly maintenance and updates on emergency public information signs located along rivers, parks, and other recreational areas were performed.

(NUREG-0654lFEMA-REP-l, Evaluation Criteria G.1 and G.2)

I This statement also: Yes No N/A

a. Certifies that parks and other recreational areas were not expanded, nor were new transient areas added to the plume EPZ. If expansions or additions were made, a X statement must be prOVided that the appropriate I t

additionai,signs were installed. I

b. Identifies organizations responsible for maintenance!

updates X

4. A statement that emergency public information materials fanhe ingestion pathway were updated and distributed. (NUREG~0654IFEMA-REP~1, Evaluation Criteria G.l and G.2)

This statement must include: Yes No N/A

a. Means of dissemination Agriculture Extension x
b. Copies of public information materials X
5. A statement that annual media program was conducted to acquaint news media with emergency plans/procedures, information concerning radiation, and points of contact for release of public information in emergency. (NUREG-0654IFEMA-REP-l, Evaluation Criterion G.S)

Tills statement must include: Yes No N/A

a. Oate(s) held  !

X

b. Agencies/organizations invited! participated X
c. Organizations that sponsored program X
d. Description of program X NOTE: In instances of poor attendance, in lieu of a meeting, a statement that program materials covering requisite topics were mailed to media representatives must be provided.

REP Program Manual Page IV-53 Apnl2012

PART IV; PROGRAM ADMINISTRATION Radiological Emergency Response Training

1. A statement that initial training and annual retraining of personnel who implement radiological emergency response plans/procedures have been accomplished. (NUREG-0654IFEMA-REP-I, Evaluation Criterion 0.5)

Statement must include the lowing for training conducted. Y( N/A

a. All required organizations were to ORO plans/procedures X
b. Scope and purpose X
c. Dates training were held X
d. Number of participants X
e. Agencies/organizations represented X
f. Agencies/organizations invited, but who did not attend. X
g. OrganizatiOns that sponsored the training. X Drills NOTE: These drills shall not be part of a regularly scheduled exercise (NUREG-0654IFEMA-REP-l, Evaluation Criterion N.2), with exception of the annual medical drill. Only non-evaluated drills need to be reported in the ALC.

I. A statement that communication drills (NUREG-0654/FEMA-REP-I, Evaluation Criterion N.2.a) were conducted:

Yes No N/A

a. \!fonthly between the State and OROs within plume EPZ X
b. Quarterly between State and Federal emergency response organizations and states within ingestion pathway EPZ X
c. Annually between NPP, State, and local emergency operations centers, and radiological field monitoring X teams ,
d. Dates of communication drills and participating X

organizations

2. A statement that radiological monitoring drill related to plume EPZ was conducted annually and included collection and analyses of all sample media (e.g., water, vegetation, soil, and air) with provisions for communication and record keeping. Where a State is responsible for more than one site, the State portion of drills need not be done at each site. (l\.T(JREG-0654/FEMA-REP-l, Evaluation Criterion N.2.d)

This statement must include: Yes No N/A

a. Dates of monitoring drills X
b. Organizations that participated X NOTE: These drills must involve personnel and resources for field team coordination and field teams.

REP Program Manual PBge IV-54 April 2012

PART* IV PROGRAM ADMINISTRATION

3. A statement that health physics drills were conducted semiannually with licensees that included response to, and analyses of, simulated elevated airborne and liquid samples and direct radiation measurements in environment. Where a State is responsible for more than one site, the State portion of drills need not be done at each site. (NUREG~0654/FEMA*REP-I, Evaluation Criterion N.2.e)

This statement must include: Yes No N/A

a. Dates of health physics drills X
b. Organizations that participated X NOTE: Health physics drills must involve personnel and resources for dose assessment.

24-Hour Staffing Yes No N/A (NUREG-0654/FEMA~REP-l, Evaluation Criterion A.I.e)

I. A statement that sufficient trained and capable staffis available to maintain 24-hour capability for protracted activation.

I j

X Emergency Facilities and EqUipment (N1JREG-0654IFEMA-REP-l, Evaluation Criteria H.3; G.3.a; J.lO.h; J.12; K.5.b)

l. Identification of facilities that are new or have had substantial changes in structure or mission since initial evaluation. A substantial change is one that has a direct affect or impact on the emergency response operations performed in those facilities.

This statement must include: I Yes No N/A

a. Verification that the facility has been evaluated, or the expected date of the evaluation I, X
2. Certification thatno substantial changes in structure or mission of previously reported facilities have occurred since initial evaluation.

This statement must affIrm that: Yes No N/A

a. There are no other new emergency response facilities, X

communications systems, or congregate care facilities

b. None of the other current facilities, communications systems, or congregate care facilities in the X plans/procedures has undergone substantial changes
3. A statement that inspection, inventory, and operational checks were made of survey instruments utilized for radiological monitoring (evacuee and emergency worker) and environmental monitoring and analysis (radiological field monitoring teams and radiological laboratory) at least once each calendar quarter and upon each use. (NUREG-0654IFEMA-REP-l, Evaluation Criterion H.I 0)

This statement must include: Yes No N/A

a. Type of equipment X
b. Quantity of equipment X
c. Location of equipment X
d. Calibration frequency L X
e. Dates of inspection/inventory check X REP Program Manual Page !V*55 April 2012

PART IV; PROGRAM ADMINISTRATION

4. A statement that survey instruments utilized for measuring radiation during environmental monitoring and analysis (field teams and radiological laboratories) were calibrated at intervals recommended by supplier of equipment (NUREG-0654IFEMA-REP-I, Evaluation Criterion H.I 0)

If calibration occurred, the statement must include: Yes No N/A

a. Type of equipment X
b. Quantity of equipment X
c. Location of equipment X
d. Dates of calibration X
5. A statement that direct-reading dosimetry has bcen tested for accuracy. All Direct-Reading Dosimeters (DRDs) shall be inspected for electrical leakage at least annually. CDV- 138s must be inspected for electrical leakage quarterly. Dosimeters shall be recharged or replaced as necessary.

(N1JREG-D654IFEMA-REP-I, Evaluation Criterion H.lD)

This statement must include: ~ Yes No N/A

a. Type of equipment X
b. Quantity of equipment X I
c. Location of equipment X
d. Dates of calibration X
6. A statement that sufficient quantities of potassium iodide (Kl) are available for emergency workers, institutionalized individuals, and if the plan calls for it, the generai public. (NUREG-0654IFEMA-REP-l, Evaluation Criterion J.l O.e) If quantities of KI were not verified by FEMA during most recent biennial exercise:

This statement must include: Yes No l'i/A

a. Amounts of KI available X
b. Storage locations X
c. Expiration date(s) , X Alert and Notification'
1. A statement that a routine siren testing program was completed pursuant to the design report. (FEMA-REP* 10)

This statement must include: Yes No N/A

a. Type of tests conducted in accordance with established schedule X
b. Dates of tests X I
c. Number of sirens tested operable and inoperable X REP Program Manual Page IV-56 April 2012

PART IV PROGRAM ADMrNISTRA nON

2. Analysis of percentage of operable sirens. (FEMA-REP~ to)

This must be at least 90 percent and include: Yes No . N/A

a. Computation of siren operability (percentage of sirens operable) for the immediately preceding calendar year.

This is determined by simple average of all regularly conducted tests employed as part of testing program (e.g., X silent, growl, full cycle). Calculations will be checked by specialist to substantiate results. I

b. Description (or calculations) of method used to calculate X

siren operability percentage

3. A statement (if applicable) that a maintenance program for residential tone alert radios has been properly implemented. (FEMA-REP-lO)

This statement must specity the type and frequency of residential tone alert radio (as part of primary ANS) tests conducted and Yes No N/A include assurances that:

a. Registers, containing list of addresses where equipment is X

located, have been updated to reflect additions or changes

b. Registers include individuals who have refused this equipment X I
c. Equipment operating checks have been completed or X offered to residents with this equipment
d. Tests identifying frequency were conducted offering the X

public a means to self-test its receivers

e. Necessary written guidance was provided that addressed: X I. General usage X
2. Self-testing frequency and method X
3. Suggested placement to facilitate efficient use X
4. Maintenance program details X
5. Telephone numbers for repair or replacement X
4. A statement specifying type and frequency of routine testing of all applicable alerting systems, other than sirens and tone alert radios. This testing must be performed at least annually. (FEMA-REP-IO)

Alerting methods may include: Yes No I N/A

a. Mobile route alerting and notification X
b. Aircraft route alerting and notification X
c. Institutional alerting mechanisms in scbools, hospitals, nursing homes, etc. I X
d. Automatic telephone dialers/switching equipment X
e. Modulated power lines X
f. Type and frequency of residential tone alert radio (as part X

of primary ANS) tests conducted REP Program Manual Page IV*57 April 2012

PART IV PROGRAM ADMINISTRATiON

5. A statement (if applicable) that a maintenance program for alerting systems other than sirens and tone alert radios (e.g., radios in schools/hospitals) has been properly implemented. (FEMA-REP-IO)

This statement must include assurances that: Yes No N/A

a. Registers, containing list of addresses where equipment is located, have been updated to reflect additions or changes X
b. Registers include organizations that have refused this equipment or information X
c. Equipment operating checks have been completed or X

offered  !

d. Necessary written guidance was provided that addressed: X I. General usage X
2. Suggested placement to facilitate efficient use X
3. Maintenance program details I X
4. Telephone numbers for repair or replacement X
6. A statement (if applicable) for exception areas requiring alert and notification methods, other than sirens and tone alert radios (e.g., aircraft andlor mobile route alerting and notification) that routes, alerting methods, and resources remain unchanged. If changes did occur, design report must be updated to reflect modifications.
7. A statement that siren sound pressure/population density requirements have been met. (FEMA-REP-10)

This statement must include assurances that: Yes No N/A

a. In areas where siren sound pressure level is less than 60 dBc, population remains below 2,000 persons per square I

X mile

b. Ifpopulation has increased to the level of 2000 persons pe~ square mile, siren sound pressure levels must be X increased and design report modified
8. A statement (if applicable) that in areas not covered by sirens, no permanent population has relocated into these areas. In areas ofEPZ where no permanent popUlation exists and transients would not frequent, a letter certirying this fact was provided with initial design report. State must certiry that this condition remains unchanged; no permanent or transient population has relocated in these areas. If relocation did occur, sirens, tone alert radios, or other means for alerting these individuals would then be required.

REP Program Manual Page IV*58 April 2012

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